Nearly six months ago, after a devastating earthquake that killed more than seven thousand people and left $5.1 billion worth of damage in Syria, the Biden administration did the bare minimum decent thing and issued an exemption for the more-than-decade-long US sanctions on the country. The sanctions had already made life for ordinary Syrians brutal and borderline unlivable at what might charitably be called the best of times, so you could only imagine the kind of deadly mayhem they would have caused in the middle of this disaster.

Half a year on, how is it going? The verdict is mixed, according to a report put out earlier this month by the Carter Center, the human rights organization founded by former president Jimmy Carter.

Based on conversations with a dozen figures from the United Nations, NGOs, banks, and other entities involved in post-earthquake efforts, the report makes clear that while the exemptions have helped, numerous obstacles to humanitarian work in the country remain as a result of the sanctions, writes the report’s author, Dr Erica Moret of the Swiss Centre for International Policy Engagement.

Unfortunately, one of those obstacles is the fact that the exemption was only put in place for six months with no mention of renewal, effectively imposing a hard cutoff date for reconstruction operations.

“It is not possible to repair damaged schools in six months. And what should we do about those projects that go over the 180-day duration?” one international organization representative is quoted as saying in the report. Other humanitarian workers deemed the six-month time frame “wholly inefficient,” states the report. This is one of the eight shortcomings of Biden’s General License 23, the sanctions exemption he issued in February 2023, that are documented in the report.

The verdict isn’t entirely negative, with the report documenting just how critical the exemption has been for those on the ground in the war-torn country. Those interviewed praise the General License for the US Treasury’s willingness to engage with humanitarian workers, for having made the process of sending remittances to Syrian families quicker and easier, for simplifying compliance requirements for banks, and for providing clarity and psychological reassurance to those carrying out humanitarian assistance. One of the long-standing criticisms of the sanctions is that their complicated and broad nature has encouraged overcompliance from banks and aid organizations, who fear legal or financial trouble from Washington if they accidentally fall afoul of them.

But the “ongoing challenges,” as the report puts it, that persist despite the exemption show this isn’t enough. The report covers several loopholes in the General License that continue to cause problems, for instance. Neither the names on the Treasury’s Specially Designated Nationals and Blocked Persons List (SDN) — individuals and companies specifically singled out by Washington for sanctioning — nor US laws against providing material support to terrorists are covered by the exemption, which means that humanitarian assistance is stifled by blocks in supply chains and payment channels.

One individual claims that fear of being ensnared in material support statutes has “been a big issue since the earthquake” for banks and companies, according to the report. And while there has been improvement in terms of payment transfers, it states, NGOs still report that financial institutions are avoiding the country due to the legal risks and bureaucratic hoops involved, making it harder to get funding for humanitarian aid.

There’s also ongoing confusion around legal definitions in the sanctions exemption, according to the report. While the General License allows transactions with the Syrian government, the wording of what actually qualifies as “the Syrian government” leaves out state-controlled entities or those in which the government holds majority ownership. Confusion likewise reigns over what kind of relief efforts are actually legally permitted, according to the report. US sanctions clamp down on anyone “considered to contribute to the reconstruction of Syria,” but the exemption allows the “restoration,” rehabilitation,” and “refurbishment” of various facilities and infrastructure — whatever those terms happen to mean. While such word choices might seem like an irrelevant matter of semantics, getting it wrong could mean legal and economic troubles.

Similar but less voluminous flaws can be found in the sanctions exemptions issued by the EU, UK, and Switzerland. Those include the identically short duration of exemptions, the length it took to put them in place, and the fact that “dual-use” goods — those that could have both humanitarian and military uses — are left out.

The findings of the report point to a host of possible next steps the Biden administration could take as Syria continues to suffer under the conditions of war, sanctions, and now deadly disaster. That might include making additional clarifications around wording in the General License and around what’s actually legally permitted for humanitarian organizations and financial institutions to do. Another obvious one would be to extend the exemption for at minimum another six months — though this would, again, stymie reconstruction efforts which are expressly forbidden in the General License if they take longer than 180 days.

That fact points to what the Biden administration and its allies actually ought to do: lift the sanctions on Syria entirely. They were already highly questionable given that they’ve failed to achieve any of their aims, while inflicting all of the suffering on ordinary Syrians instead of the repressive, corrupt, and undemocratic rulers they’re meant to punish. The fact that despite exemptions, they continue to stifle reconstruction work and so load up even more suffering on innocent Syrians makes them completely unjustifiable.